Matter of Board of Educ. v. Arlington Teachers Ass’n, 41 N.Y.2d 571 (1977)
An arbitration award stemming from a collective bargaining agreement between a school district and a teachers’ association can only be overturned on public policy grounds when it contravenes a strong public policy, almost invariably involving an important constitutional or statutory duty or responsibility.
Summary
The Teachers Association sought to confirm an arbitration award that prevented the School District from assigning specialist teachers outside their area of expertise, based on a collective bargaining agreement. The School District argued that the award violated public policy by restricting the board’s control over the educational program. The Court of Appeals held that while collective bargaining agreements do involve some relinquishment of educational control, only awards contravening a strong public policy (involving constitutional or statutory duties) can be set aside. The court found no such strong public policy violation in this case, affirming the confirmation of the arbitration award.
Facts
The collective bargaining agreement between the Arlington School District and the Teachers Association included Article XXXIII, which stated that both parties recognized the importance of competent specialists and agreed to make every effort to provide the district with necessary specialists, promising no reduction in the number of specialist teachers unless there was a decrease in enrollment.
Despite no decrease in enrollment, the School District reassigned four specialist teachers to subject areas outside their specialty, effectively reducing specialist instruction. The Teachers Association initiated a grievance procedure, which eventually led to arbitration.
Procedural History
The Teachers Association petitioned to confirm the arbitration award. Special Term initially refused to confirm the award, finding the arbitrator’s interpretation of Article XXXIII contradictory. The Appellate Division reversed, granting the petition to confirm the award. The School District then appealed to the New York Court of Appeals.
Issue(s)
Whether an arbitration award, based on a collective bargaining agreement provision regarding specialist teacher assignments, violates public policy to the extent that it restricts the board of education’s control over the educational program of the district.
Holding
No, because the arbitration award did not contravene a strong public policy involving an important constitutional or statutory duty or responsibility. The school district’s agreement to maintain a certain level of specialist services did not violate any strong public policy.
Court’s Reasoning
The Court of Appeals stated that while school districts cannot delegate or bargain away duties or responsibilities so important that statutes require decisions be made by educational authorities, not every collective bargaining agreement that impairs the flexibility of management is against public policy. The court emphasized that “incantations of ‘public policy’ may not be advanced to overturn every arbitration award that impairs the flexibility of management of a school district.” The court further clarified, citing Matter of Susquehanna Val. Cent. School Dist. [Susquehanna Val. Teachers’ Assn.], 37 NY2d 614, 616-617, that arbitration under the terms of a collective bargaining agreement is a permissible forum for resolving disputes between a board of education and a teachers association, absent clear prohibitions derived from constitution, statute, or common-law principles.
The court distinguished this case from situations where arbitration would be forbidden because statutes require decisions be made by educational authorities. The court reasoned that the School District had the power to conclude that specialist services were necessary and to agree to maintain them for the duration of the collective bargaining agreement. The award was not vulnerable because arbitration awards are not reviewable for errors of law or fact.
The court also referenced the Susquehanna case, which rejected the argument that staff size was within the board’s exclusive prerogative and therefore not arbitrable. The court stated that in this case, “As interpreted by the arbitrator, the clause required the district to maintain an agreed upon level of specialist services.” The court held that no strong public policy was violated by such a provision in a short-term collective bargaining agreement.